1. Dear Secretary Kerry,
As a resident of the state of Michigan, as well as an undergraduate student studying
Environmental Policy and Political Science at Central Michigan University, I have my concerns over the
pair of nearly 100-year-old idled St. Clair River oil pipelines. My first concern is the integrity of the
company. Over the years Plains All American Pipeline has had an unconvincing safety track record.
The company spilled oil three separate times across the U.S. in 2015 — 500 barrels in Midland,
Texas on Jan. 1; 100 barrels near the Madison-Bond county line in Illinois on July 10; and spilled
105,000gallons of oil into the Pacific Ocean off Southern California on May 19. These spills follow a
long history of safety and environmental violations by the company in both the United States and
Canada, according to news reports and Environmental Protection Agency records. Plains All American
Pipeline assures the nearly 100-year-old pipelines "have no previous history of environmental
problems and would conduct safety inspections before using the old lines again.” But when they
spilled the 105,000 gallons on the beach near Santa Barbara, California, Plains All American made
all sorts of assurances that they were using state-of-the-art integrity management systems. However,
the Pipeline Hazardous Materials Safety Administration (PHMSA) determined that corrosion was the
failure. Therefore, “assurances” are not enough and the integrity of the company is sub-par at best. The
integrity of the company is important because, the St. Clair River is a fast-moving river and is
considered a "high consequence area" by the Federal Pipeline Hazardous Materials Safety
Administration (PHMSA). Chemicals spilled at Marysville could reach the City of St. Clair’s water
intake in about four hours; the St. Clair flats wetlands and Lake St. Clair within 21 hours. A crude
spill would be catastrophic to Michigan’s public health, economy, and environment. In Michigan, we
are no strangers to oil spills. In 2010, Michigan was home to the worst inland oil spill in United
States history, under the responsibility of Enbridge, who shares a similar poor safety record to that of
Plains All American Pipeline.
The main drinking water intake for Detroit is at the north end of Belle Isle, right downstream
from the pipelines. Water intakes for other communities on both the U.S. and Canadian sides are all just
downstream as well. 44 million people on both sides of the Great Lakes rely on this water. The sport
fishery and boat recreation on Lake St. Clair is second to none and is home to some of the best
recreational sport fishing for Walleye, Yellow Perch, Muskellunge, and Smallmouth Bass in the world.
It has been voted by Bassmaster magazine as the best bass lake in the U.S. and is home to the highest
catch rate of muskellunge in the world. The Lake Huron ‐ Lake Erie Corridor system (HEC) consists of
other waters and adjacent lands encompassed by the St. Clair River, the St. Clair Delta, Lake St. Clair,
and the Detroit River. This region contains a diverse range of aquatic habitats associated with coastal
wetland, riverine, deltaic, and shallow near shore and open‐lake environments including critical
spawning, nursery, and forage habitats for multiple fish species and other aquatic organisms. The St.
Clair River is home to the 'most significant lake sturgeon spawning area in the entire Great Lakes'. This
is important because lake sturgeon are listed as a threatened species in both the U.S. and Canada. Studies
demonstrate that the St. Clair River serves as an important fish migration route during lake sturgeon
spawning runs. Walleye tracking studies also document significant movement of fish through the
connecting channels of Lake St. Clair, and Lake Huron. Similar studies of the movements of Chinook
salmon further show use of the connecting channels and Lake St. Clair as a migratory route from Lake
Michigan‐Huron into Lake Erie. This, and other studies clearly show that disruption of natural migration
routes and/or loss of connectivity (which an oil spill would) to spawning and nursery habitats by water

2. control structures placed within the St. Clair River would cause significant damage to the Great Lakes
Fishery.
Since the pipelines were built prior to the National Environmental Policy Act (NEPA), none of
the laws requiring things such as an Environmental Impact Statement applied to the construction of
these pipelines. Furthermore, I understand under federal rules, if a company receiving a transfer of an
existing permit intends to operate essentially unchanged from that previously permit, you, the State
Department do not intend to conduct an environmental review of the application, which I believe is a
mistake on your part. The previous, 1918 permit and the correspondence from 1971 allows for “crude
and other liquid hydrocarbons.” Heavy crude oil would be disastrous. It is more corrosive, bringing a
greater liability and chance of an oil spill to the two-century-old pipelines, which have never even seen
an environmental assessment. With the area supporting world class fisheries, serving as an economical
and recreational fishing boon, as well serves as a home to threatened species--these pipelines need to be
scrutinized at a level where there is a meaningful environmental impact assessment. This should hold
especially true on pipelines nearly 100-years-old. A break in the pipelines would be catastrophic to
the Great Lakes region, the environment, and the local economies, completely undermining the
national interests of the United States.
If Plains All American, says they do not plan to use the two pipelines other than in the event
of an increase in energy demand (which I don’t buy), then I don’t see how two, unused pipelines
would be a benefit to our country’s national interest. Tom Konik, Marysville public safety director, has
been quoted in a Detroit Free Press article stating, "Those pipelines, the pipelines in question haven't
been used since the 1980’s.” Since the 1980’s, we have seen increases in energy demand and more
additions of new pipelines. We currently already have enough pipelines to handle an increase in
energy demand. If these pipelines served the United States national interest, we would still be using
them. In addition, by allowing the permit, you are giving them the go-ahead to use the pipeline
whenever they want. Just because Plains All American Pipeline says they aren’t going to use it,
doesn’t mean they have to legally abide to that statement. Under no certainty can we hold the
company’s statement with a hundred percent confidence. No plans today, does not mean no plans for
tomorrow. And if they do decide to continuously use them, the potential dangers and costs of using
the pipelines increase drastically, and simply outweigh the benefits of its potential use.
I urge you to reconsider the approval of these pipelines.
Sincerely,
Tim Minotas